ML20033A242
| ML20033A242 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/30/1981 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| References | |
| TAC-43461, NUDOCS 8111250018 | |
| Download: ML20033A242 (7) | |
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Docket No. 50-344 TERA
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'!g7p.o' Mr. Bart D. Withers OELD Vice President Nuclear IE-3 008W A
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Dear l'r. Withe'rs:
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,J. koL4 We wish to thank you for the comments regarding the draft Facility Attachment prepared for the application of IAEA safeguards at the Trojan tluclear Plant. The attached observations relate to each specific coment enclosed with the August 19, 1931, let er from fir.
t Brochl of your organi2 ation.
With regard to the recomendation that NRC reevaluate the necessity and difficulty of implenenting the Facility Attachmnt through the use of license conditions, we have concluded that the issuance of such conditions is practicable and that, in fact, it is the best way to assure effective inplenentation. We note, in this connection, that the relevant provision (10 CFR S 75.8) was included in the regulation to assure licensees a means for resolution of disputes outside of enforcenent proceedings. We continue to believe that this will serve our mutual interests in implementing the US/IAEA Safeguards Agreenent.
It is our intent to proceed v.ith the development of appropriate license conditions as expeditiously as possible.
I Sincerely, hb OO.nai si ned by:
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Robert A. Clark, C hief Operating Reactors Branch #3 Division of Licensing
Enclosure:
Observations I
cc w/ enclosure:
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Portland General Electric Company cc: Multnomah County Library Social Science and Science Department
.i 801 S.W. 10th Avenue i
Portland, Oregon 97205 Michael Malmros, Resident Inspector U. S. Nuclear Regulatory Commission l
Trojan Nuclear Plant P. O. Box 0 Rainier, Oregon 97048 1
Robert M. Hunt, Chairman Board of County Commissioners s
Columbia County i
St. Helens, Oregon 97501 i
Donald W. Godard, Supervisor Siting and Regulation Oregon Department of Energy Labor and Industries Building Room 111 Salem, Oegen 97310 J
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Observations Related To Comnents Received From The Trojan Nuclear Plant (Broehl) - 8/19/81) On The Draf t fdcility Attachment i
r Item 1
- The 70-day advance notification is spelled out clearly in 10 CFR ! 75.11(c)(1). There is no need to deal with IAEA approval since t$ere is no suggestion that such approval is required.
I Similarly, the initiation of the modifications does not require prior notification or review by the IAEA or under 10 CFR 75 by NRC.
The licensee's concern that some of the areas of notification spelled out in the Facility Attachment (code 2.2) are too broad appears to be well taken. Clarifying details where necessary will be addressed in the development of the license conditions.
Item 2
- While we recognize that all the nuclear material at Trojan is located inside the security ience, it appears in everyone's best interest o use the less restrictive definition for the MBA that is currently in code 3.1.1 of the Facility Attachment (FA).
Item 3 In Code 3.1.3 of the FA, the nominal timing of at least once per year for physical inventory taking applies only to Fuel other than that contained in the core...".
Tne nominal timing for physical inventory taking of naterial in the core is shown as "As soon as possible after each refueling and before the reactor is closed again."
In either cace, a Material Balance Report (MBR) and Physical Inventory Listing (PI' ) would be required.
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Item 4
- Identification of each assembly by serial number is necessary to i
prepare the Physical Inventory Listing (PIL) required in conjunction I
with each physical inventory. Whether this is done from the 1
operators' records or by physically verifying the serial numbers during the taking of the inventory is lef t to the discretion of I
the licensee.
Item 5 - Granting an emnption under Section 75.3 is not automatic. When the IAEA grants an exemption for material from IAEA safeguards per i
Article 35 of the Agreement, the Convaission will in turn exempt such material from the requirements of Part 75.
It should be noted, how-t i
J ever, that this material may still be controlled under Part 70.
l Item 6
- Code 5.1.2 refers to records maintained of material included in the pnysical inventory. See item 4 Item 7
- We agree with the licensee conwent that operating records identifying individual assembly locations by KMP (Ref. Code 3.1.2) would, in 1
general, be satisfactory for detenaining changes in quantities and composition of nuclear material. A possible exception may be the i
need to know specific core locations for the calculation of produc-tion or burnup.
In any case, the DIQ indicates that operating records which show the specific location o,f all assemblies are currently being maintained in the form of tag boards, reactor core 1
maps, etc.
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I Item 8 - Some of what appear to be inconsistencies in the reporting require-ments are probably the result of writing the instructions in a manner which satisfies both the IAEA and our domestic requirements.
Mr. Sparks of NRC will contact the licensee to discuss in detail all problems related with the reporting requirements.
i The 742 and 742C forms are required for IAEA purposes af ter each physical inventory.
Inventories must be taken at least once annually for material not in the reactor and af ter each refueling for the material in the core. To meet domestic requirements, the instructions call for an additional Material Balance Report (MBR) from those facilities who take only an annual inventory. This MBR is based on book values, and is to be submitted six months subsequent to the annual physical inventory.
Computer output of individual fuel ass:',bly data may be used in con-junction with or in place of the 742C fann if all pertinent IAEA data are included.
I The 741 form is necessary to report all inventory changes including burnup and decay.
For domestic purposes a breakdown of the country of origin is included in the 741 fon".
Comparing values on successive 742 forms does not provide all the necessary information.
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Item 9 - We agree with the licensee's comment, and will endeavor to have the word " precise" in code 6.2.2 of the FA either removed or changed.
Item 10 - Nonnally, assemblies in GiPB (fuel in the reactor core) ar2 carried by the IAEA at shipper's values; however, as indicated in the footnoteohpage6oftheFA,ifPuproductionandburnupare J
reflected by the operator prior to removal of the assemblies from the core, such adjusted values should be shown. We agree that some modification should be made to Code 6.3.2 to reflect this possibility.
Item 11 - Code 7.3 relates to the IAEA inspection effort and indicates that the man-days of inspection effort shown is based on a number of i
assumptions. One of these in Section (d) assumes tnat for material being shipped for reprocessing the IAEA will be given the opportunity, if they wish, to identify the assemblics at the reactor before they are shipped and correlate this with checks made at the reprocessing i
.I plant.
In the event that spent fuel is shipped for reprocessing, we co not feel that this is an unreasonable request.
Item 12 - Code 7.4 relates to the scope of routine IAEA inspections. The use of the term " identification" in 7.4.2 and 7.4.3 does not require the licensee to verify the identity of each assembly, but only that the i
IAEA may, if they wish, make such a verification during their routine inspections. Tais presumes that they have the technical capabilities l
to do 50.
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Item 13 - We agree with the licensee comment and will change the reference to the " Auxiliary Building" to " Fuel Building."
Item 14 - The seals referenced in C3de 7.4.3 applies to the possible use of IAEA seals during the IAEA verification of inventory changes at Flow KMPs. For the convenience of both the IAEA and the operator, arrangements may be made, where agreeable to both parties, to permit the IAEA to attach their seals on dormant fuel in containers.
This would eliminate the necessity of opening these containers for reverification in subsequent IAEA inspections.
The "other seals" referred to in Code 7.4.4 include, in addition to the seals mentioned above, those other IAEA seals which may, when agreed to 4 both the IAEA and the operator, be temporarily utilized for convenience during the IAEA inventory verification.
Item 15 - The reference to Article 73(d) in Code 7.5 adequately identifies this as the IAEA's own equipment. The licensee is a party to any specific arrangements for the use of such equipment, and can assure that any such arrangements will not unduly interfere with plant operations or schedules.
Item 16 - The list of services in Code 7.9.1 seems to be straightforward.
However, trere requested, more clarification can be included in the license conditions.